VIETNAM 2026-5

Ho Chi Minh City High-Level People’s Court, 24 August 2023

(S C v. R Joint Stock Company)

24 - 08 - 2023

VIETNAM 2026-5

Yearbook Yearbook Commercial Arbitration, S. W. Schill (ed.), Vol. LI (2026)
Jurisdiction Viet Nam
Summary

On appeal, the Court set aside the first-instance decision that had denied enforcement of a SIAC award, dismissing the award debtor’s objections. The Court held that the tribunal had acted within the scope of the parties’ agreement, and that the award debtor’s disagreements in respect of evidence evaluation, contractual interpretation, or application of law concerned the merits of the case, which the Vietnamese courts cannot re-adjudicate when reviewing foreign arbitral awards for enforcement.

Related topics
101

The court discusses the determination and relevance of the place where the award was made (in a foreign State or another contracting State.

Award made in the territory of another (Contracting) State (paragraphs 1 and 3 - first or "reciprocity" reservation)
301

The court discusses the principle that the procedure for the enforcement of awards under the Convention is governed by the lex fori, as well as procedural issues (such as the competent enforcement court) not falling under the specific cases of ¶¶ 302-307.

Procedure for enforcement in general
306

The court discusses the applicable period of limitation for seeking enforcement of an award.

Period of limitation for enforcement
500

The court discusses the overall scheme and/or pro-enforcement bias of the Convention.

Grounds for refusal of enforcement in general
502

The court discusses the principle that the merits of the award may not be reviewed and that the court may only carry out a limited review of the award to ascertain grounds for refusal.

No re-examination of the merits of the arbitral award
VIETNAM 2026-5